Our Commitment to Privacy
Applicability of Privacy Policy
The Information We Collect and How We Use
It
Cookies and Related Data
Employers, Schools and Other Sponsors
Aggregation of Data
Information We Collect from Children
How to Access or Correct Your Information
Changes to Our Privacy Policy
Your Privacy Policy under California Law
How to Contact Us
Our Commitment to Privacy — At Reflective Learning, protecting your privacy is important to us. We understand you may have questions or concerns regarding your personal information and how it will be used. With this in mind, we have developed this Privacy Policy. To make this Privacy Policy easy to find, we link to it from the home page of our web site and from other pages on the Web Site. This Privacy Policy and our Terms and Conditions constitute the Legal Notices that govern the use of this web site.
Please note that there is a section of this Privacy Policy, below, that discusses the Information We Collect from Children via the Web Site and how we use that information.
This Privacy Policy applies to the following documents, protocols and programs (each, a “Program”) and web sites (collectively, the “Web Sites”): Reflective Learning at www.reflectivelearning.com, ResilienceOnline, LeadershipOnline, DietResilience at www.dietresilience.com, ReflectiveHappiness at www.reflectivehappiness.com, EmployeeExcellence at www.employeeexcellence.com, ReflectedBestSelf, PowerfulPresenter, R4PoweR Teen Resilience, ReflectiveCoaching at www.reflectivecoaching.com, and any other Reflective Learning web site (unless that site has a different privacy policy)
Applicability of Privacy Policy — This Privacy Policy applies only to information we collect through each Web Site. For information on how we handle information collected by traditional means (e.g., via telephone, from invoices or customer information forms, etc.), please contact us as described below in the section titled “How to Contact Us".
The Information We Collect and How We Use It — On some of the pages on the Web Site, you may be able to conduct personal assessments, submit queries, download information, or request that we provide services. Some of the information we collect is personal information, while other information we collect is not personal information. The types of personal information we may collect when you access the Web Site include the following
We use this information to provide our services to you via this Web Site and related Web Sites. We provide your information back to you. If your account is through a company, school or other sponsor, we provide the information back to your company, school or other sponsor. We also use this information to better understand how you and others use our Web Sites so that we may improve our Web Sites. We also aggregate information we collect from the Web Site, remove your personal information, and share the aggregated non-personal information with third parties. We may also disclose user information to government authorities, and to other third parties when we are compelled to do so by government authorities. We may also disclose user information when we have reason to believe that someone is causing or may cause injury or damage to property.
Cookies and Related Data — Some of the information we collect via the Web Site is gathered and maintained through the use of “cookies” and other methods. A “cookie” is a small file that is saved on your computer and which may contain information about you, such as your user name and password, or about your use of the Web Site, such as the page you most recently visited. As a result, we are able to (i) recognize you when you access the Web Site so that you do not have to re-enter your personal or other information each time you visit the Web Site, (ii) customize and personalize the content and Programs we make available to you, (iii) maintain the “state” of your current visit (e.g., to maintain a list of your most recent questions, searches or the items in your “shopping basket”), and (iv) alert you to new features of the Web Site, contests, prizes and polls.
In addition we may collect certain non-personal data in connection with the Web Site. For example, we may collect information on the browser that you use to access the Web Site, the operating system that you are running, and certain information about the web site you accessed immediately before you accessed our Web Site.
Employers, Schools and Other Sponsors — For each employer, school or other entity that sponsors users of this Web Site (“Sponsor”), we generally track each user’s identifier (e.g., a user name set by you or the Sponsor) and the user’s password. We ask users and Sponsors not to use personal information in their user identifiers or passwords. We may provide to any Sponsor the responses and scores of its users, including what sections of a Program have or have not been completed by a particular user.
Aggregation of Data — As we discuss above, we may aggregate your responses to our Programs, and combine them with other non-personal data of you and/or other users to create anonymous aggregated data, and provide the anonymous aggregated data to third parties for research and marketing information. Moreover, we may aggregate some or all of the data collected or developed by users of a particular Sponsor, and then provide that data to that Sponsor. For any user, we may aggregate your non-personal data with the non-personal data of our other users. We also collect and analyze general traffic patterns within our Web Site to help maintain the flow and content of the Web Site, and we may use some or all of this anonymous aggregated information to support our commercial activities or for any other reason.
In addition, we may collect other personally identifiable information about you through the Web Site to learn more about you and to provide you with services. Except as specified in this Privacy Policy or as otherwise authorized by you (including, for example, to perform credit card transactions), we will not disclose your personally identifiable information to any third party, unless required to do so by law; provided, however that we may (i) use such information to support our customer satisfaction initiatives, (ii) from time to time disclose such information to other companies that are affiliates of Reflective Learning, and (iii) we may disclose such information to a third party that is a successor to all or part of our business, provided that such third party agrees to comply with the provisions of our Privacy Policy with respect to the use of your information.
We may from time to time send information or offers to the email address you provide to us. If you prefer not to receive such email, please follow the procedures set forth at the end of each email explaining how you can have your email address removed from the applicable email list. Alternatively, you may contact us at optout@reflectivelearning.com to “opt-out” of receiving such email.
Information We Collect from Children — One of our Programs, R4Power Teen Resilience (“R4Power”) is directed at teenagers and children under the age of 13. Our other Programs are not directed at children (“Non-R4Power Programs”). We comply with the provisions of the Children’s Online Privacy Protection Act (“COPPA”), which applies to the online collection of personal information from children under the age of 13.
Among other things, COPPA requires us to obtain verifiable parental consent prior to collecting personal information from individuals under the age of 13 for any portion of our Web Sites that are directed to children.
We do our best not to collect personal information from children under the age of 13. However, we may collect personal information from children under the age of 13 if the child pays for R4Power with a credit card, or if the child provides us with personal information in response to the questions asked by the Program. Moreover, a school or other sponsor may mistakenly provide us with personal information about a child if the school uses the child’s name or other personal information as part of the child’s user name or password.
Users who sign up for R4Power directly from the Web Site are required to pay for the Program with a credit card. The use of a credit card to pay for a good or service online is treated under COPPA as a form of parental consent. We ask each school or other Sponsor who signs up a user not to provide any personal information about their users, and we ask the school or sponsor to obtain verifiable parental consent in accordance with COPPA if they want to provide us with personal information about their users.
Any parent who wants to provide us with parental consent may do so either through a hard copy form that is signed by the parent or guardian, and mailed or faxed to us at the addresses stated below in “How to Contact Us”, or by responding to an email that we send to the parent or guardian’s email address. Parents may also revoke their consent, or tell us to stop collecting personal information from their children, by contacting us as stated below in “How to Contact Us”. Parents may review any personal information we have collected from their children by contacting us as stated below in “How to Contact Us”.
The section of this Privacy Policy entitled, “The Information We Collect and How We Use It” applies to the information we collect from both children and adults in our R4Power Program. One difference is that we do not provide to third parties (other than a school or any other sponsor of the user) any personal information from any individual that we know is under the age of 13. We do not condition a child’s participation in R4Power on the child’s disclosure of more personal information than is reasonably necessary to participate in the Program.
In any case, we do not share any personal information collected from children under the age of 13 unless the recipient (a school or another sponsor of the user) has agreed to maintain the confidentiality, security and integrity of the user’s personal information. In addition, each parent has the right to consent to our collection and use of their child’s personal information, while saying no to our disclosure of the information to third parties, including a school or other sponsor of the user.
For our Non-R4Power Programs, we do not knowingly solicit or collect information from any individuals under the age of 13, nor do we intend that any of our Non-R4Power Programs to be provided to individuals under the age of 13. If you believe that we have inadvertently collected any such information, or provided any such Non-R4Power Programs, products or services to individuals under the age of 13, please contact us immediately so that we may delete the information.
Our Commitment to Data Security — To prevent unauthorized access to your personally identifiable information, maintain data accuracy, and ensure the correct use of such information, we have put in place certain physical, electronic and managerial procedures to safeguard and secure the information we collect, although no system is completely secure. We urge you to take adequate precautions to protect your personal data, which should include never sharing your username and password with anyone.
How to Access or Correct Your Information — You can access your personally identifiable information that we have collected through the Web Site and that we still maintain by contacting us as described below in “How to Contact Us.” You can correct factual errors in your personally identifiable information by sending us a request that credibly shows that our records are incorrect, although we may refuse such requests in our discretion. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access to your personally identifiable information or permitting you to make corrections
Changes to Our Privacy Policy — We reserve the right to revise this Privacy Policy from time to time in our discretion. If we modify this Privacy Policy, we will post the revised Privacy Policy, which will take effect immediately upon posting, and we may attempt to notify you of such change through the email address you provide to us. It is your responsibility to periodically review this Privacy Policy.
Your Privacy Rights under California Law — California Civil Code Section 1798.83 states that any of our users who are California residents may request certain information regarding our disclosure of their personal information to third parties for direct marketing purposes. If you would like to make such a request, please contact us by email, phone or fax as stated in the “How to Contact Us” section of this Privacy Policy.
How to Contact Us — Should you have questions or concerns about this Privacy Policy or any other matter pertaining to our privacy practices, please call or fax us at the numbers stated below, or send an e-mail to the following address: info@ReflectiveLearning.com. You may also send us a letter to the address that follows:
Reflective Learning, LLC
Attention: Customer Service
Radnor Station Office Building
Bldg. #2 Suite 306-310
290 King of Prussia Road
Radnor, PA 19087
Telephone: (215) 629-9210
Telefax: (215) 629-9213